DINAMICA · Financial Analysis & Research Platform
Privacy Policy
| Controller | 1013millibar Europe |
| Location | Sweden |
| Privacy contact | support@dinamicaresearch.com |
| Effective date | 27 September 2026 |
| Last updated | 27 September 2026 |
1. About This Privacy Policy
DINAMICA is a financial analysis and research platform that organizes financial, market and analyst information and produces proprietary analytical metrics and classifications. This Privacy Policy explains how personal data is processed in connection with the DINAMICA website, account and service (the “Service”).
This Privacy Policy applies to personal data relating to DINAMICA users and, where relevant, other identifiable individuals whose information is processed in connection with the Service. It does not describe financial or market information about companies merely because that information appears in DINAMICA; information becomes personal data when it relates to an identified or identifiable individual.
This Privacy Policy should be read together with the DINAMICA Terms of Use and applicable disclosures. Those documents address contractual use of the Service and the nature and limitations of DINAMICA’s financial analysis; this Privacy Policy addresses personal-data processing.
2. Who Is Responsible for Your Personal Data
DINAMICA is operated by 1013millibar Europe, a Swedish sole proprietorship. 1013millibar Europe (“DINAMICA”, “we”, “us” or “our”) is the controller of personal data processed for the purposes described in this Privacy Policy, except where another party acts as an independent controller for its own processing.
Questions about this Privacy Policy or requests concerning personal data may be sent to support@dinamicaresearch.com. Where a third-party provider acts as an independent controller for a particular activity, its own privacy information may also apply to that processing.
3. Personal Data We Process
The personal data we process depends on how you use DINAMICA and which features are available and enabled. The principal categories are described below.
Account and profile information
Email address; internal user and account identifiers; account creation and status information; email-verification status; and optional profile or interface preferences such as display name, preferred currency, locale, timezone and onboarding status.
Authentication and security information
Authentication events; sign-in and session information; password-reset and verification events; security and audit information; IP address, user-agent or similar technical information where processed by our authentication or infrastructure systems. DINAMICA does not intentionally store users’ plaintext passwords.
Subscription and billing information
Where paid subscriptions are offered: plan and subscription status; customer, order or provider references; subscription start, renewal, cancellation and paid-through information; trial status; and billing or payment status. DINAMICA is not intended to store full payment-card numbers, CVV codes or complete card credentials.
Portfolio and transaction information
Where you use Portfolio: portfolio identifiers and names; securities held; BUY/SELL transaction records; trade dates; quantities; prices; fees; currencies; and related portfolio history.
Derived portfolio information
Calculations derived from portfolio data, such as current quantity, average cost or cost basis, position lots, realized or unrealized profit and loss, market value, portfolio weight and position history or cycles.
Favorites, settings and monitoring preferences
Securities you choose to follow or save; saved filters or criteria; display preferences; user-configured thresholds; and alert definitions or delivery preferences where those features are available.
Usage and technical information
Information necessary to operate, secure and troubleshoot the Service, such as error, reliability, performance and security events. If product analytics are enabled, minimized or aggregate information about use of website or product features may also be processed as described in Section 7.
Communications and support information
Service emails, support requests, correspondence and any information, screenshots or attachments you choose to provide when contacting us.
Administrative and privacy records
Records of material account actions, Terms or notice versions where relevant, suspension or termination, privacy-rights requests, identity-verification steps used for those requests, and records necessary to document how a request or security matter was handled.
Third-party individual financial or professional information
Where the Service displays financial-research data concerning identifiable individuals, such as publicly reported insider information, this may include a person’s name, title or role, issuer relationship and publicly reported transaction information.
Data we do not intentionally collect for investor profiling
DINAMICA v1 is not designed to build an investor suitability or risk profile. We do not intentionally request, solely for that purpose, information such as risk tolerance, investment objectives, desired investment return, loss tolerance, net worth, household income, investment horizon or investment experience. We also do not intentionally infer an investor suitability or risk profile from portfolio holdings, transactions, Favorites, searches or analytical settings.
4. How We Obtain Personal Data
We may obtain personal data from the following sources:
- Directly from you, for example when you create an account, enter portfolio transactions, configure preferences, request support or exercise a privacy right.
- Automatically through your use of the Service, for example authentication, session, security, reliability and technical information generated when DINAMICA is used.
- From DINAMICA’s own calculations, where user-provided portfolio information is used to calculate related portfolio metrics.
- From service providers, for example authentication, infrastructure, subscription, payment or communications providers where those services are used.
- From financial and data sources, where DINAMICA receives financial-research information that may identify company insiders or other individuals.
5. How and Why We Use Personal Data
We process personal data only for defined purposes and on an applicable legal basis. The legal basis depends on the processing activity. The table below summarizes the principal purposes anticipated for DINAMICA.
| Purpose | Examples | Principal legal basis |
|---|---|---|
| Create and operate your account | Registration, authentication, account access and requested profile settings. | Performance of a contract / steps requested in connection with the Service. |
| Provide requested product features | Portfolio, Favorites, settings, user-defined thresholds and alerts where available. | Performance of a contract. |
| Calculate portfolio information | Cost basis, P&L, market value and other portfolio calculations requested through the Portfolio feature. | Performance of a contract. |
| Protect DINAMICA and its users | Security monitoring, abuse prevention, investigation of suspicious activity and protection of systems. | Legitimate interests in securing and protecting the Service and its users; legal obligations where applicable. |
| Operate and troubleshoot the Service | Reliability, error and technical telemetry necessary to maintain the Service. | Legitimate interests in operating, maintaining and improving the reliability of the Service. |
| Manage subscriptions and access | Plan, subscription status, renewals, cancellations and access rights. | Performance of a contract; legal obligations where applicable. |
| Comply with law and maintain required records | Accounting, tax, regulatory, legal-claims and compliance records where required. | Legal obligation and/or legitimate interests, depending on the context. |
| Provide support and service communications | Responding to requests, security notices, account messages and operational communications. | Performance of a contract, legitimate interests or legal obligation, depending on the communication. |
| Process public insider/professional information | Displaying and organizing publicly reported financial-research information about identifiable company insiders. | Legitimate interests in providing and organizing financial research information, subject to applicable data-protection rights. |
Legitimate interests
Where we rely on legitimate interests, we consider the purpose of the processing, its necessity and the potential impact on individuals. We do not use legitimate interests as a generic substitute for another legal basis. You may have a right to object to certain processing based on legitimate interests, as described in Section 11.
Consent
DINAMICA does not use consent as a blanket legal basis for operating the Service. Where a specific activity is based on consent, you may withdraw that consent for future processing as described in Section 11. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
6. Portfolio and Financial User Data
If you choose to use DINAMICA’s Portfolio functionality, DINAMICA processes information describing or derived from securities positions, transactions and portfolio activity associated with your account. Internally, DINAMICA treats this information as “Financial User Data” and applies elevated safeguards because it may reveal sensitive information about a user’s financial activity, even though it is not automatically a special category of personal data under the GDPR.
Financial User Data is used to provide user-requested portfolio recording, calculation, organization, history and monitoring functionality. This may include calculations such as current quantity, cost basis, realized or unrealized profit and loss and market value.
Access to Financial User Data is intended to be restricted according to user ownership, role and operational need. Administrative access to an account does not by itself imply unrestricted access to portfolio information. Where support or security work requires access to Financial User Data, access should be limited to what is reasonably necessary for that purpose.
7. Analytics, Cookies and Similar Technologies
DINAMICA may use cookies, local storage, session storage or similar browser technologies that are necessary to provide authentication, security, session continuity and user-requested preferences. Necessary technologies are not used for unrelated advertising purposes.
Operational telemetry
We may process minimized technical information needed to detect errors, protect the Service, investigate abuse and maintain reliability. Operational telemetry is not intended to create a behavioral investment profile.
Product and website analytics
DINAMICA v1 is not intended to use behavioral advertising, cross-site advertising tracking or session replay within the authenticated product. Before publication, DINAMICA will perform a cookie and browser-storage scan of the production implementation. A separate Cookie Policy or consent-management mechanism will be used if required by the technologies actually deployed and applicable law.
8. Service Providers and Other Recipients
We may disclose or make personal data available to service providers and other recipients where necessary for the purposes described in this Privacy Policy. Access is intended to be limited to the relevant purpose and subject to appropriate contractual, technical or organizational safeguards where required.
Relevant categories may include:
- database, authentication and infrastructure providers;
- web hosting and application infrastructure providers;
- analytics providers where analytics are enabled;
- subscription and payment providers where paid plans are offered;
- email and communications providers where communications are sent;
- security, support or professional service providers where necessary;
- professional advisers, auditors or legal advisers where reasonably necessary; and
- public authorities, courts or other recipients where disclosure is required or permitted by applicable law.
The current architecture uses Supabase for core database/authentication infrastructure and Vercel for web application hosting/runtime. Other providers are identified here when relevant to the processing actually carried out through the Service.
Some providers may act as processors on DINAMICA’s instructions, while others may act as independent controllers for particular activities. The legal role is assessed according to the relevant processing rather than assumed solely from the provider’s commercial label.
9. International Data Transfers
DINAMICA is intended to operate through a Swedish controller. The primary Supabase project database is currently configured in Stockholm, Sweden. This does not mean that every processing activity performed in connection with DINAMICA occurs only in Sweden or only within the European Economic Area (“EEA”).
Some service providers may process personal data in the United States or other countries outside the EEA. Where Chapter V of the GDPR applies, DINAMICA will use an applicable transfer mechanism and safeguards as required, which may include an adequacy decision or the European Commission’s Standard Contractual Clauses together with additional assessment or measures where appropriate.
DINAMICA seeks to minimize unnecessary international movement of Financial User Data. In particular, Financial User Data is intended to remain primarily in the core Supabase data layer and should not be unnecessarily persisted in deployment artifacts, general-purpose application logs, analytics systems or development environments.
10. How Long We Keep Personal Data
We keep personal data only for as long as reasonably necessary for the purpose for which it is processed, or for a longer period where required or justified by applicable law, security, dispute resolution or the establishment, exercise or defense of legal claims. Different categories therefore have different retention periods or criteria.
| Category | Retention approach |
|---|---|
| Account and profile | Generally retained while the account remains active. Following an account-deletion request, active account/profile data is deleted according to the deletion workflow, subject to limited lawful exceptions. |
| Portfolio and Financial User Data | Generally retained while the account exists and the Portfolio feature is used. On account deletion, user-linked portfolio, transaction, lot, allocation, position-cycle and derived portfolio data is intended to be removed from active systems, subject to a specific lawful retention need. |
| Favorites, settings and alerts | Generally retained while the account exists and deleted with the account, unless a limited lawful exception applies. |
| Authentication sessions | Invalidated or deleted when no longer required, including as part of account deletion. Security/audit records may follow a separate limited retention period. |
| Security and operational logs | Retained only for as long as reasonably necessary for security, reliability, troubleshooting and applicable legal requirements. |
| Subscription and billing records | Subscription-state information is minimized when no longer needed. Certain billing, tax, accounting, dispute or Merchant-of-Record records may be retained for periods required by applicable law or by the relevant independent controller. |
| Support records | Retained only for as long as reasonably necessary to handle the relevant support request, related claims and applicable legal requirements. |
| Terms/privacy request records | May be retained in minimized form where reasonably necessary to demonstrate acceptance history, compliance, request handling or legal claims. |
| Backups | Deleted information may remain temporarily in protected backups until those backups expire through the applicable rotation cycle. Deleted data should not be intentionally restored into ordinary active use. |
Subscription cancellation, account termination and deletion are different
Cancelling a paid subscription normally stops future renewal or changes paid access according to the subscription terms; it does not by itself delete the DINAMICA account or portfolio data. Account suspension or termination also does not necessarily constitute immediate erasure. A separate account-deletion or privacy-erasure workflow applies when personal data is to be deleted.
11. Your Privacy Rights
Subject to the GDPR and other applicable law, you may have rights concerning your personal data. These rights are not all absolute and their application can depend on the type of processing and legal basis.
Access
You may request confirmation of whether we process your personal data, a copy of relevant personal data and the information required by applicable law.
Rectification
You may ask us to correct inaccurate personal data. Common profile or preference information may be editable directly in the Service. Corrections to transaction history may use a controlled edit, delete or correction workflow to preserve data integrity.
Erasure
You may request deletion of personal data where the applicable legal conditions are met. A self-service Delete Account function is intended to initiate deletion of user-linked active data, subject to lawful retention exceptions.
Restriction
You may request restriction of processing in circumstances provided by law. Restriction may require a manual privacy workflow rather than deletion.
Data portability
Where applicable, you may receive personal data you provided to us in a structured, commonly used and machine-readable format. DINAMICA intends to support practical export of common account and portfolio data. The legal portability right does not necessarily apply to every DINAMICA-derived analytical result.
Objection
Where processing is based on legitimate interests, you may have the right to object on grounds relating to your particular situation. Objections are assessed against the relevant processing and applicable legal requirements.
Withdraw consent
Where a specific activity is based on consent, you may withdraw consent for future processing. This does not affect processing lawfully carried out before withdrawal.
Direct marketing
If DINAMICA introduces optional direct marketing, you may object to or opt out of that marketing. Marketing preferences do not prevent service, security or other necessary account communications.
Complaint
You have the right to lodge a complaint with a competent data-protection supervisory authority. For a Swedish controller, the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY) is particularly relevant, without limiting rights you may have to complain to another competent authority under applicable law.
How to exercise your rights
Where self-service controls are available, you may use them to manage common account data, export information, manage optional communications or initiate account deletion. You may also contact support@dinamicaresearch.com to exercise a privacy right or make a request that cannot be completed through the Service.
We may take reasonable steps to verify your identity before disclosing, changing or deleting personal data. Verification will be proportionate to the risk and we will not request identity documents by default where less intrusive verification is sufficient.
DINAMICA will track applicable statutory response periods and any legally permitted extension. Requests are generally handled without charge, subject to the conditions and exceptions permitted by applicable law.
Requests from non-users
A person does not need to hold a DINAMICA account to contact us about personal data that DINAMICA may process about them. This is particularly relevant to identifiable individuals appearing in third-party financial or professional datasets. Such requests will be assessed according to the source, purpose, legal basis and applicable rights or exemptions.
12. Security
DINAMICA implements technical and organizational measures intended to protect personal data appropriate to the nature of the information and the applicable risks. Measures are intended to include authentication and access controls, user isolation, controlled privileged access, secure handling of infrastructure credentials, protected communications, security monitoring and incident-response procedures.
Financial User Data receives elevated internal protection. DINAMICA’s design is intended to prevent one user from accessing another user’s portfolio or other user-linked information and to limit privileged access according to operational need.
No technical or organizational system can guarantee absolute security. If DINAMICA becomes aware of a personal-data breach, it will assess, document and respond to the incident and make notifications to supervisory authorities or affected individuals where required by applicable law.
13. Children and Age Eligibility
DINAMICA v1 is intended only for individuals aged 18 or older. DINAMICA does not knowingly provide accounts to individuals under 18.
To apply this eligibility rule, DINAMICA may ask a user to confirm that they are at least 18. DINAMICA does not intend to collect a full date of birth or identity document solely to establish the 18+ requirement where a less intrusive method is sufficient.
If we reasonably determine that an account belongs to an individual under 18, we may restrict or terminate the account and apply the appropriate data-deletion process, subject to limited retention required or justified by applicable law, security or claims. Parental consent does not make an under-18 individual eligible for a DINAMICA v1 account.
14. Changes, Contact and Complaints
Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes in the Service, our processing activities, providers or applicable requirements. The current version will identify its effective date and last-updated date. Where a change materially affects how personal data is processed, DINAMICA will provide any notice, choice or other measure required by applicable law.
Contact
For privacy questions or requests, contact: 1013millibar Europe Sweden Email: support@dinamicaresearch.com
Complaints
You may contact DINAMICA if you have concerns about how your personal data is handled. You also have the right to lodge a complaint directly with a competent supervisory authority. For a Swedish controller, the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY) is particularly relevant. Contacting DINAMICA first is not a condition for exercising a statutory right to complain.